PCIT v. Indian Farmers Fertilizer Cooperative Ltd. (2026) 308 Taxman 185 (SC) Editorial : PCIT v. Indian Farmers Fertilizer Cooperative Ltd [2025] 179 taxmann.com 410 (Delhi) (HC)

S. 14A: Disallowance of expenditure-Exempt income-Delay of 469 days-SLP dismissed on account of delay and also on merits. [R.8D, Art. 136]

High Court held that no disallowance could be made under section 14A if no exempt income was earned by the assessee. On SLP by the revenue, the Court held that  since there was a delay of 469 days in filing SLP, which had not been explained satisfactorily, and moreover the order of the Income Tax Appellate Tribunal was that of remand to assessment officer, SLP was  dismissed.

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